ML20073J992
| ML20073J992 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/12/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 22171, 82-01-#5, 82-1-#5, MCAR-55, NUDOCS 8304190485 | |
| Download: ML20073J992 (8) | |
Text
Y 4
consumers Power James W Cook C0mp20Y Vice President - Projects, Enginee,ing and Construction General offices: 1945 West Parnell Flood, Jackson, MI 49201 + (517) 788-0453 April 12, 1983 82-01 #5 b'{.) Y 3b. 3 m Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 DEFICIENCIES IN ELECTRICAL ACCESSORIES ASSOCIATED WITH SAFETY-RELATED MATERIAL REQUISITIONS FILE:
0.4.9.57 SERIAL: 22171
References:
J W Cook letter to J G Keppler, Main Steam Isolation Valves, Final Report, Serial 17558, Dated July 30, 1982 The referenced letter was the final 50.55(e) report concerning deficiencies associated with main steam isolation valve actuators, logic cabinets and control panel inserts. On March 11, 1983, W R Bird notified R Gardner that CPCo was revising MCAR 55 to include additional equipment identified, as a result of corrective action follow up, to have a similar deficiency. This letter provides the revised MCAR and an interim report as to the status of additional corrective action to resolve this issue.
Another report, either interim or final, will be sent on or before July 15, 1983.
6.vQ. Cook g
JWC/WRB/lr Attachments: (1) MCAR-55, Revision 1, dated March 11, 1983 (2) MCAR-55, Revision 1, Interim Report 5, dated April 5, 1983 CC: Document Control Desk, USNRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant
)3]
"~
8304190485 830412 M'"' /
OC0483-0005A-MP01 gDRADOCK 05000329 PDR APR 1 5 083
-?
-s 2
Serial 22171 82-01 #5 CC CBechhoefer, ASLB Panel FPCowan, ASLB Panel JHarbour, ASLB Panel AS&L~ Appeal Panel MMCherry, Esq MSinclair BStamiris CRStephens, USNRC WDPaton, Esq, USNRC FJKelley, Esq, Attorney General SHFreeman, Esq,- Asst Attorney General WHMarshall GJMerritt, ESQ, TNK&J INPO Records Center f
f 9
?
OC0483-0005A-MP01
. ~.
g~
QUALITY ASSURANCE PROGRAM serial 22171 MANA!EMENT CORRECTIVE ACTION REPORT Pcs -[lN52 MCAR-1 10818i 55-Revision 1 REPORT NO.:
7220 3/11/83 JOB NO.:
O NO.:
_ DATE:
1 DESCRIPTION * (Ir:cluding References):
Main Steam Isolation Valves (MSIVs) were supplied by Fluid Systems Division (FSD) of Gulf & Western Manufacturing Company under Purchase Ordtr 7220-M-ll8A(Q) issued 8/22/74. The design for the electrical components associated with these valves does not appear to conform to the channel separation criteria in Reg. Guide 1.75 to the extent required by the FSAR; also, satisfactory seismic qualification reports have not been submitted for these electrical components. The electrical components of concern a g g g g g g S g g identified as follows:
(con't. on page 2) 1)
Take the appropriate corrective action to make the design and the hardware conform to the requirements of Regulatory guide 1.75 and IEEE standard as committed in FSA1.
2)
Obtain the required equipment seismic qualification.
3)
Add the above mentioned Class lE electrical components associated with the MSIVs t )
the Qualification Test Status Report (QTSR) as outstanding items to be qualified.
(con't. on page 2)GPtngineering REFERRED TO:
O Construction O OA Management O
O Procurement Revision 1 was communicated to the NRC ISSUED BY:
3 by WRBird on 3/11/83.
foi PmedQA Engma om I
E
- NOTIFIED CLIENT:
ll REPORTABLE DEFICIENCY:
lPotentially O NO
! '*[YE I
4Mf3 l
pm.cian a-om I
O CAUSE:
CORRECTIVE ACTION TAKEN:
AUTHORIZED BY:
om AAPO DISTRSUTION PROJ DISTNSUTION OTHER DISTIMOUTION MOR or construction car coNSTR oc ENGR MGR oF oA. TPo FORMAL REPORT TO CUENT MOR OF ENOMEERNO CUENT GPO OA MGR (If Section11 Applies)
Da MGR OF PMOCUREMENT PFOCE LAPO. OA MOR MOR OF PRCM OPERATIONS PROJECT CONSTR MGR SFPD OA MGR MOR OF QUAUTY ASSURANCE PRCuECT ENGINEER CORRECTIVE ACTION IMPLEMENTED construction uGR PRcuEc7 uGR ENONEERNG MOR PA(M PROCUREMEN7 MGR suppuER QUAUTV MOR SrTE MOR OE SUPERVISOR VERIFIED BY
- Desenbe in space provided and attach reference document.
pm.ci QA Engmoer Date AApocoo -
Section Number Page of
MCAR 55 - Rev%$ i O i Page 2 of 2 1.
DESCRIPTION (continued) 1)
Actuator, limit switches and wiring 2)
Actuator terminal. box and conduits 3)
Safety-related actuator solenoid valve 4)
All components and wiring of the logic cabinets and control panel inserts, except for the pressure transducer digital readout.
Appendix Al to Specification 7220-M118A(Q), 51.19.20, states:
The equipment included in this specification shall be designed, built, tested, and l
shall conform in accordance with the latest applicable AGMA, ANSI, ASTM, IEEE, and l
NEMA Standards.
Subsequent review by Project Engineering of purchases other than valve orders revealed L
that electrical accessories / devices were procured without having specified the proper
}
requirements.
In some instances the vendors claim they were not aware that these devices perform a safety function, and therefore, they did not supply these devices as Q-equipment. However, these devices have been designated and wired by Bechtel as Class lE equipment.
I.
RECOMMENDED ACTION (continued) 4)
Determine why qualification for the electrical components was not detected by MCAR 25 re-review. Add to the QTSR any other deficiencies pertinent to equipment qualification identified on NCRs.
5)
Engineering shall determine what other purchases this specification or similar valve specifications for electrically operated Q-listed valves were used in which associated electrical components were purchased with the valves.
Engineering shall review the identified purchases to ensure that the seismic qualification documentation and electrical separation requirements satisfy the FSAR commitments, and take appropriate corrective action as required.
6)
In order to preclude recurrence, Engineering shall determine, identify and define the root cause of this problem.
7)
Define and establish the required guidelines for specifying Class lE equipment. These guidelines should be used to develop a list to include all Q-equipment / instruments / devices.
8)
Each discipline (Mechanical, Control Systems, Electrical, Civil, Nuclear, and Architectural) is requested to review its MRs and specifications (per guideline of Item 7 ab'ove) to ensure that equipment and accessories are specified in accordance with project requirements.
9)
Bdsed on the results of the review of Item 8 above, develop a plan to ensure that safety related design uses only Class 1E devices / equipment or provides equipment isolation as required.
10)
All of the above review shall be properly documented and auditable.
i l
{
i
,..,n,
..,..,.,.,.,,,w. g.
n~,,..,.~.--._,-3...-
o A2ta hment 2 Ii072i Serial 22171 Ii0668 82-01 as Management Corrective Action Report (MCAR)
Subject:
MCAR 55, Revision 1 Deficiencies in electrical accessories associated with safety-related material requisitions.
Interim Report 5
-Date:
April 5, 1983 s
Project:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Joh 7220
(
Description of Deficiency i
l The initial scope of the MCAR 55 included main steam isolation valves (MSIVs) and actuators supplied by Energy Products Group (EPG), a division of Gulf and Western Manufacuring Company under Purchase Order i
7220-M-118A(Q). Major safety-related electrical components of the MSIV system (the actuators, logic cabinets, and the control panel inserts) were.found to be nonconforming to the separation criteria of Regulatory Guide 1.75, Quality Assurance Program, as required by 10 CFR 50 Appendix
[
B, or ANSI 45.2 and the project seismic requirements.
[
The' scope of MCAR 55 has been expanded as a result of project's commitment to review safety-related material requisitions for the similar nonconformances. A review of four additional equipment packages i
[M-125C(Q) nuclear stainless steel valves 150 through 400 pound ratings 2-1/2-inch and larger, M-149(Q) air handling units, M-150(Q) air filtering units, and M-154(Q) HVAC isolation valves] that include electrical accessories has revealed that some non-Class lE devices have been wired into Class IE circuits.
Summary of Investigation and Historical Background l
As a result of MCAR 55, further review was conducted for selected l
safety-related material requisitions. Contacts with four equipment package vendors and review of available documentation confirmed that some non-Class lE devices have been wired into Class lE circuits.
Analysis of Safety Implication A detailed analysis of safety implication was performed for the MSIVs in previous MCAR 55 reports. Detailed analysis for each purchased item of the four additional equipment packages has not been performed and will be addressed in future reports. Potential safety concerns exist for some of these systems to perform their safety function as described in applicable FSAR sections because the integrity of the Class lE power and control
.,_7--_.
__ n,_
y.7,
-.._ g m.2
Ii0721 MCAR 55, Revision 1 Ii0668 Interim Report 3 Page 2 circuits may be degraded by the inclusion of non-Class IE devices if not l
properly isolated.
Probable Cause Preliminary investigation of the problem indicates:
a.
Some material requisitions for safety-related equipment do not directly reference the requirements of Regulatory Guide 1.75 and IEEE-384 regarding identification and separation of the Class lE and non-Class 1E functions and devices, b.
Some vendors provided non-Class lE devices for functions which they understand to be nonsafety-related.
c.
Vendor documents frequently do not distinguish between Class lE and non-Class lE functions and devices.
I d.
Electrical schemes and control logics for this equipment are usually l
developed on the assumption that the electrical accessories provided as part of satety-related material are Class lE.
j-Corrective Action l
All recommended corrective actions associated with the original issue of MCAR 55 related to the MSIVs have been completed except for recommended Action 5.
It is now included under the new recommended Action 8 to review all safety-related material requisitions that include procurement of electrical components and accessories for similar potential l
nonconformances and deficiencies.
The following action plan is being developed to resolve the expanded scope of MCAR 55.
Develop a checklist for review of safety-related material requisition a.
requirements and vendor design adequacy.
l b.
Review all safety-related material requisitions to the checklist.
(
c.
Review vendor electrical design (those designs where both Class 1E and non-Class 1E components are present) for adequacy and clarity based on system functional requirements.
I l
=....
Ii072i MCAR 55, Revision 1 ii0668 I"*'ri= ** Port 5 Page 3 d.
Review Bechtel electrical design (those designs where both Class IE and non-Class IE components are used in vendor design) interface with vendor electrical design.
e.
Identify any inconsistencies. Qualify vendor components, modify vendor design and/or Bechtel interface design.
f.
Development of a list identifying all safety-rel'ated components will be addressed in future interim reports.
Reportability The final report on MCAR 55, issued July 28, 1982, committed to the further reviews of equipment not covered in either MCAR 55 or MCAR 46.
On March 11, 1983, Mr. W.R. Bird of Consumers Power Company notified Mr. R. Gardner of the NRC that deficiencies in electrical accessories / devices associated with other equipment had been identified.
l l
l l
,..,9 7 w.
._% : ww 7p
~ e-
- + + * -.
s_
=
o.
+*=*=-r-
- w e ov +*===.g q w * - * * * = * % ? -* *
- r* ~ w + v ece
I i
MCAR 55, Revision 1 Ii0668 Ii072I Interim Report 5
[
Page 4 Submitted by:
[
T.G."Ballweg /
Mechanical Group Supervisor mm J/G. Kovach Electrical Group Supervisor
& fE-n h G. Singh F
ControlSystemsGroup/Supervisor Approved by:
N ProjectEngineer{
E.M. Hughes
/
Concurred by Msf M.'F. Fravel Mechanical Chief Engineer
,8 M
W R.L. Cas'tleberry C/
Electrical Chief Engineer E.
. O _' " - -
Control Systems Chief Engineer h).
E.H. Smith
~
Engineering Manager h M.A. Dietrich Project Quality Assurance Engineer TCB/SP/lb(M) 032305/9 l
r t
h J
_ _..,